Last August, the final rule overhauling the Part 23 airworthiness standards for general aviation airplanes officially went into effect.
Now, the FAA has issued 63 means of compliance (MOCs) for Part 23 that will foster faster installation of innovative, safety-enhancing technologies into small airplanes, while reducing costs for the aviation industry, FAA officials say.
On May 11, the FAA published a notice of availability in the Federal Register accepting 63 MOCs to Part 23 that are based on consensus standards published by ASTM International.
The MOCs listed in the notice are an acceptable means, but not the only means, to comply with the applicable regulations in Part 23, amendment 23-64, for normal category airplanes, FAA officials note. The public comment period ends July 10, 2018.
The FAA participated with the general aviation industry in developing these consensus standards. The agency accepted 46 of the ASTM consensus standards as MOCs without change; the other 17 MOCs are a combination of the ASTM standards and FAA changes.
Accepting MOCs — based on consensus standards — to Part 23, amendment 23-64, is consistent with the Small Airplane Revitalization Act of 2013 and the FAA’s stated intent in issuing the overhauled airworthiness rules, officials said.
A summary of MOCs accepted by this notice is available on the FAA website. Guidance for proposing additional means of compliance to Part 23 for FAA acceptance is provided in Advisory Circular 23.2010-1.
It is a given many folks at the FAA are bright and intelligent. However many of them fall on the the other end of the spectrum. A fine example of the other end is found in a FAA PowerPoint presentation that can be found on the Internet. Look it up. (How Airports Make Money and What’s New in Compliance) dated April 17, 2012. In the presentation the sources of revenue for Airports add up to 256 present. Now if my recollection is correct you can never have more than 100 present.
Battling with the FAA is not easy or simple especially when they themselves fail to follow Federal regulations. I can say that without fear of reprisals. In a letter from the FAA (dated 11/23/2015) they redacted 27 pages in entirety to my FOIA request regarding a simple airspace change. The letter stated I had 45 days to appeal the denial. The appeal was done in a timely manner as prescribed by law on January 11, 2016. Here is my concern why is it the FAA has yet to respond to my appeal. By FOIA law they are required to respond within 30 days. It has now been almost 30 months without a response. Good luck ladies and gentlemen dealing with our government systems.
Now what is interesting my FOIA request was about an airspace change at KSLE. The change was unwarranted and not needed from my prospective and created a hazardous condition. In fact two additional changes have been implemented do to my efforts. If the FAA can not follow their own procedures, policies and guidelines, then this nation has some serious problems to deal with.
Take a look at the airspace at KLWS. It was implemented by NPRM FAA 2017-0986. I made a comment to the NPRM and the FAA response to my comment was in fact humorous.
Have a good day and may God Bless America.
This has been around a long time, but this is an example of what what the FAA has for Maintenace Inspectors. Mind you, there are some great guys who are well qualified, but this guy has no business being a maintenace inspector, or any other kind of inspector for that matter. If you havent seen it, you will probably shake your head in disbelief.
Watch the top one, which is part 1 of the deposition, then watch part 2.
https://www.youtube.com/watch?v=0W_42CGdgrw
https://www.youtube.com/watch?v=x9GB399Hoi0
Richard,
Agree . . . you have to use the language they are familiar with when you describe what you want. Don’t say “non-serviceable”, say instead “sealed recombinant gas no service required battery – exactly like the one in your car” (Unless he is driving a 1940 Ford.) I would LOVE to be able to do this in my C150, the #680 battery is so much better, much more reliable, lighter and far less expensive than the Gill or the Concorde antiques – but we can’t use them yet. And the Gill and Concorde batteries spill acid and fumes which rot away the expensive and unobtanium battery box – what a bargain!
If I ask real nice, can I get you to share a copy of your final paperwork so I can redo it for my 150?
Best Regards,
I submitted a 337 for Field Approval for a lightweight non-serviceable PMA’d battery to be installed in a Super Cub where the normal battery is installed. This battery is approved in Super Cubs as long as it is installed under the seat in accordance with an STC. First, the FAA wanted to mknow why I wanted to install a battery that wasn’t any good. The inspector thought non-serviceable meant it wasn’t any good. I had to write a 5 page maintenance manual including cover sheet and table of contents listing the 16 required items they have for maintaining the battery in airworthy condition. All the items were marked N/A except one which wanted to know if the battery was dead. The answer I put was “attempt to charge it and if it wouldn’t take a charge, replace it.”
This government bureaucracy has cost the aviation insustry so much money I hesitate to even say billions of dollars with stupid regulations and some, but not all, employees who couldn’t make it in the real world. By the way, the first time I submitted the “maintenance manual” on the above battery installation, it was rejected because I didn’t put the date on the cover sheet. Unbelievable stupidity.
One answer to your heartache with field approvals is to seek a DER approval instead of a Field Approval.
The “field approval” and “AMOC” log jam must be broken. I dont need an 18 week lead time to get on a schedule for someone to come and tell me “they need more information”. I also don’t need to continue to pull the wings from Piper Pawnees to inspect the wing attach lugs on airplanes that have not sprayed or slopped chemicals in every nook and cranny (and were converted to glider tow planes 30 years ago!!) which resulted in corrosion. Ironically, we have NEVER found any deterioration via an eddy current inspection for the lugs requiring inspection, yet it happens every two years. The dollars just keep flowing and the cost of everything continues to become unreachable to many. The industry (pilots, owners, A&Ps and IA’s) is being forced into a corner and reality and logic is nowhere in sight. If a “top down intervention” does not happen in the near future, everything we know as (certified) GA will be gone to the ages or only for the rich and famous.
ACCEPTABLE does not mean APPROVED. Acceptable only means it is a way you can submit paperwork to them for an installation or modification for them to maybe approve it. Anything helps though.
Hey, manufacturers, how about fuel gauges that are accurate, at least on the ramp. Car drivers would never accept a situation where you had to dip the gas tank to see how much gas you have. Why should pilots??
Installed the CiES digital senders, along with an Aerospace Logic digital gauge in my C175 and “what you see (on the gauge) is what you have”(in the tanks). The accuracy of “modern stuff”, should not be taken lightly…
Where’s all the press releases about the sub $200K certified Vans Aircraft and Glassairs?